AFIA disappointed in BSE measures

International Review Panel’s BSE Report: actions ignore U.S. protection system; draws inappropriate conclusions, says U.S. feed association
February 11, 2004

The American Feed Industry Association (AFIA) has expressed its disappointment with recommendations by an international panel on Bovine Spongiform Encephalopathy (BSE) precautions the U.S. should consider, particularly as they relate to the feed supply.

AFIA says the panel has largely ignored aggressive measures in place, which have effectively prevented the spread of the animal disease in the U.S. It has also discounted findings of the preeminent study by the Harvard Center for Risk Analysis which underscored that domestic safeguards minimized significantly the likelihood of BSE ever taking hold in U.S. cattle. Perhaps, its most glaring error was to focus on the BSE scenario in the United Kingdom in arriving at some highly questionable, unscientific conclusions.

"The panel’s comparison of feed safeguards in this country to the BSE situation in Europe is completely off-base and extremely misleading," says AFIA President David Bossman. "That connection disregards the high level of compliance that the industry has recorded in adhering to FDA’s feed rule. Safeguards implemented as far back as 1989 and the industry’s near perfect regulatory compliance—99.6%—make the U.S. situation vastly different from the situation in Europe. The European dilemma necessitated more draconian measures—ones that would be more costly and unnecessary here. The risk level overseas was much greater."

The panel’s call to remove all Specified Risk Materials from all feeds is also unjustified as is its proposal to ban all mammalian and poultry protein from ruminant feeds.

"Those decisions reveal a serious omission of sound science in advancing measures that would seriously impact global food production," Bossman stated. "Discontinuing the use of mammalian protein products is irresponsible. Retaining these valuable products is absolutely essential at a time of burgeoning demand for food animal protein. This is especially true in the developing countries. Keeping the products in the feed chain is supported by strong science. They are safe, nutritious and wholesome. Their use is practical both from an economical and environmental standpoint."

AFIA supports FDA’s overall proposals for strengthening the BSE feed rule. In fact, the Association suggests even further broadening of what the agency is proposing for restricted use protein products (RUPP). AFIA wants to see registration of all producers, renderers, transporters, feed makers, brokers and farmers who use or handle the material. This would provide complete traceback of how and where the material is used. Furthermore, record retention should be expanded from one to six years, with FDA review, and all entities should be required to adhere to third part certification of compliance. Certification would support government-based inspection and would provide an additional safeguard in this nation’s defenses against the animal disease.

AFIA is highly supportive of recent federal actions to further protect the U.S. beef supply. The Association believes that there cannot be too may industry or government science-based precautions, firewalls or safety program redundancies when it comes to BSE prevention. Future decisions on the safety of the feed and food supply must continue to be based on sound science. Those actions should not be forthcoming from political pressure, unfounded concerns over public perception or decisions other countries have made based on their respective BSE situations.

AFIA is confident that the U.S. beef supply is safe and that actions, taken by FDA and earlier by the U.S. Department of Agriculture, will further protect consumers and reassure our international trading partners.

AFIA is the only national trade association exclusively representing the livestock, poultry and pet feeding and ingredient industries in the United States. AFIA is also the recognized leader on international industry developments. The Association represents over 600 companies whose several thousand facilities make more than 70% of the nation’s primary feed and pet food. Membership also includes 25 state feed and grain associations and more than a dozen affiliated national and international associations.

For additional information, contact AFIA, 1501 Wilson Boulevard, Suite 1100, Arlington, Va. 22209. Tel: 703/524-0801. Fax: 703-524-1921. E-mail: